Knowing about patent violations
Global-Tech Appliances v. SEB S.A.
In brief
The Court upheld the judgment against Pentalpha, accepting willful blindness as evidence of knowledge but rejecting mere indifference to a known patent risk.
- Where it stands
- Decided
Decided 8-1 · May 31, 2011 · Opinion by Justice Alito
- What it’s about
- SEB accused Pentalpha of encouraging others to violate its patent.
- Who it affects
- Pentalpha's judgment remains in place, and induced-infringement claims require proof that the accused party knew the encouraged acts infringed.
Summary: written with AI from the case record.
What it's about
The Court ruled that this requires knowing the encouraged acts infringe a patent—not merely ignoring a known risk that one exists—and upheld the appeals court’s judgment because the evidence supported finding that Pentalpha knew through deliberate avoidance.
The case concerned the federal patent-law rule against inducing infringement.
Question presented
Does induced infringement under the patent clause require knowledge that the induced acts constitute patent infringement?
What the Court decided
Holding
1. Induced infringement under §271(b) requires knowledge that the induced acts constitute patent infringement. 2. Deliberate indifference to a known risk that a patent exists does not satisfy the knowledge required by §271(b). Nevertheless, the Federal Circuit’s judgment must be affirmed because the evidence in this case was plainly sufficient to support a finding of Pentalpha’s knowledge under the doctrine of willful blindness. 594 F. 3d 1360, affirmed.
- Result
- Affirmed
The Court's reasoning
The Court said someone who encourages infringement must know that the acts they encourage infringe a patent; merely ignoring a known risk that a patent exists is not enough. It upheld the judgment because the evidence plainly supported finding that Pentalpha knew through deliberate avoidance (willful blindness).
The vote
From the opinions
“Willful blindness is not knowledge; and judges should not broaden a legislative proscription by analogy.”
What's next
The Federal Circuit's judgment remains in place. Lower courts apply the knowledge rule the Supreme Court announced in induced-infringement cases.
Documents
Opinions
Audio
Docket activity
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AI analysis generated: Impact Analysis
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Audio Recording added: Oral Arguments - Global-Tech Appliances, Inc. v. SEB S.A.
Opinion added: Opinion
More questions
- What did Justice Kennedy object to?
- He agreed that the law requires knowledge but argued that willful blindness cannot replace it and that the appeals court should review the evidence again.
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.